Kelly A. Lenahan-Pfahlert | lenahanpfahlertk@ballardspahr.com |  215.864.7311 | view full bio

Kelly focuses her practice on white collar defense and complex civil litigation.  Kelly has substantial experience in litigating BSA/AML issues on behalf of financial institutions relating to both discovery and liability, assisting with AML-related internal investigations

On October 9, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued a renewal of its Geographic Targeting Order (“GTOs”), which require U.S. title insurance companies, including their subsidiaries and agents, to collect, retain, and report specified information regarding certain non-financed residential real estate transactions involving legal entities. The new GTO is effective from October 10

On August 28, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released an advisory (FIN-2025-A003) alongside a comprehensive Financial Trend Analysis (“FTA”), shining a spotlight on one of today’s most significant illicit finance risks: the integration of Chinese Money Laundering Networks (“CMLNs”) into the operations of Mexico-based transnational criminal

On August 4, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice FIN-2025-NTC1 (the “Notice”) to address mounting concerns over regulatory risks related to convertible virtual currency (“CVC”) kiosks, also known as cryptocurrency ATMs. This action is part of a broader response to the rise in money laundering, fraud, and other financial crimes linked to

On June 25, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued three orders designating CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. (collectively, the “Designated Institutions”) as “financial institutions of primary money laundering concern.” These measures, taken under the FEND Off Fentanyl Act of 2024

In a significant move to curb illegal activities at the U.S. Southwest border, the Financial Crimes Enforcement Network (FinCEN) issued an alert, on May 1, 2025, concerning oil smuggling from Mexico into the United States, orchestrated by notorious cartels such as the Cartel Jalisco Nueva Generacion (CJNG). This alert highlights the crucial role of

On May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under section 311 of the USA PATRIOT Act, suggests prohibiting U.S. financial institutions from forming or maintaining correspondent banking relationships with Huione Group. The

In a significant policy shift, Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation By Prosecution,” on April 7, 2025, signaling a change in the Department of Justice’s (DOJ) approach to digital assets. The memorandum, outlines a move away from the previous administration’s enforcement efforts, which the memo called “reckless” and “ill conceived

On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking, Housing, and Urban Affairs with a bipartisan 18-6 vote, paving the way for Congressional approval. The bill was introduced and sponsored by Senator

On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in cryptocurrency activities. This recent directive, issued under Acting Comptroller Rodney Hood, rescinds the requirements set by Interpretive Letter 1179 from November